KMCO, Inc. - Executive Summary |
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KMCO, Inc. Risk Management Plan - Executive Summary 1. EXECUTIVE SUMMARY KMCO, Inc. is committed to operating in a manner that is safe for KMCO workers, the public, and the environment. KMCO provides tolling services to their customers. These service include Distillations and Chemical Processing and Manufacturing. As part of this commitment, KMCO has established a system to help ensure safe operation of the processes at this facility. One of the requirements of the RMP rule is to submit a risk management plan (RMPlan) describing the risk management program at KMCO. This document is intended to satisfy the RMPlan requirements of the RMP rule and to provide the public with a description of the risk management program at KMCO. 1.1 Accidental Release Prevention and Emergency Response Policies KMCO is committed to the safety of KMCO workers and the public, and to the preservation of the environment, through the prevention of accidental releases of hazardous substances. KMCO implement s reasonable controls to prevent foreseeable releases of hazardous substances. In the event of a significant accidental release, our trained Emergency Response personnel will respond in order to control and contain such releases. KMCO evaluates each situation, evacuates workers as necessary, and contacts the local emergency response organizations to prevent and/or reduce the consequences of the release, if/when necessary. 1.2 KMCO and Regulated Substances KMCO handles five listed toxic substances by the RMP rule in sufficient quantities to be covered by the RMP rule: 7 Ethylene oxide stored for use in customer tolling processes. KMCO also handles Propylene Oxide, Formalin (formaldehyde solution), and Ethylenediamine. As a result of the use of regulated substances at KMCO the following toxic chemicals are covered by the RMP rule: Tolling Processes for a variety of customers. All are regulated under EPA RMP Program 3. Ethylene Oxide --- 185,000 lbs. max. storage/on-site for pro cessing Propylene Oxide --- 245,000 lbs. Ethylenediame --- 80,000 lbs. Formaldehyde Solution (Formalin) --- 15,000 lbs. NOTE: There are no RMP listed flammables at the facility. 1.2 Offsite Consequence Analysis KMCO performed off-site consequence analysis (OCA) to estimate the potential for an accidental release of a regulated substance that could potentially affect the public or the environment. The OCA consists of evaluating both worst-case scenarios (WCSs) and alternative release scenarios (ARSs). KMCO does not expect a worst case release scenario to ever occur. An ARS represents a release that might occur during the lifetime of a facility like KMCO. ARSs help the LEPC improve the community emergency response plan. We have shared that information with the LEPC and other organizations involved in emergency response activities. It is also available to the public. If you are interested in this information, please contact our RMP Coordinator at (281) 328-3501. The main objective of performing the OCA is to determine the distance at which certain effects might occur to the public because of an accidental release (called the endpoint distance). The following effects could occur at the endpoint distance. At distances less than the endpoint distance, the effects should be greater; at distances greater than the endpoint distance, the effects would be less. Worst-case Release Scenario The worst-case release scenario for toxic substances is failure of a tank car containing 168,200 pounds of Ethylene Oxide (EO). As stated above, KMCO does not expect a worst case release scenario to ever occur. The computer modeling program used was DEGADIS Ver. 2.1. The scenario is based on the following: the product is liquified under pressure, release duration of 10 minutes, release rate of 16,820 lbs./minute, with no mitigation measures, rural surrounding (terrain generally flat and unobstructed), weather information was obtained by utilizing DEGADIS defaults. Although there are mitigation measures, such as deluge systems at the tank car rail spur(s), the model was done with no mitigation measures to determine a worst case scenario that could include city water service interruptions or low pressure. The calculation resulted in an estimated distance to an endpoint as: 6.81 miles. Since this facility is located in a populated area, the toxic cloud formed by the release would reach offsite public receptors. Alternative Release Scenarios for EPA RMP Listed Toxics Again, DEGADIS Version 2.1 was utilized to calculate the release scenarios, except for Formaldhyde Solution. Ethylene Oxide - an alternative scenario could be a rupture of a two (2) inch diameter liquid unloading pipe from a tank car to the storage tank. The material is liquified under pressure, release duration of 60 minutes, with mitigation measure of an enclosed space, in direct contact with outside air. The EO storage tank area has a concrete "bunker" around the tank that is 26 feet long I/D, 20 feet wide I/D, 6 feet deep, and the wall thickness is 12 inches. The estimated distance to toxic endpoint was: 0.56 miles. Ethylenediamine - a toxic alternative scenario could be a rupture of a three inch hole in a tote bin or other storage vessel with no mitigation measures. An estimated distance to toxic endpoint was 0.03 miles. Formaldehyde solution - the modeling programs used could not accurately calculate an endpoint since the material is a aqueous solution. The model is/was not realistic because of the evaporation rates the programs apply to chemicals cannot be applied to aqueous solutions. Therefore, RMP*Comp was utilized for this scenario. An toxic alternative scenario could be a rupture of a three inch diameter pipe from the unloading of a tank truck to a tank. The initial operational flow of 100 gallons/minutes, with an operational pipe pressure of 30 psi, release rate of 11,900 lbs./minute, with no mitigation measures calculates to an estimated distance t o toxic endpoint of 0.4 miles. Propylene Oxide (PO)- an alternative scenario could be a rupture of a three (3) inch diameter liquid unloading pipe from a tank car to the storage tank. With a release duration of 18 minutes the estimated distance to toxic endpoint was: 0.07 miles. 1.3 Accidental Release Prevention Program and Chemical-specific Prevention Steps The following is a summary of the general accident prevention program in place at the KMCO plant. Because processes at the KMCO plant are regulated by the EPA RMP regulation are also subject to the Occupational Safety and Health Administration (OSHA) process safety management (PSM) standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program. Employee Participation KMCO encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation range from updating and co mpiling technical documents and chemical information to participating as a member of a process hazard analysis (PHA) team. Employees have access to information created as part of the KMCO plant accident prevention program. In addition, KMCO has a number of initiatives under way that address process safety and employee safety issues. These initiatives include a Safety Committee to promote both process and personal safety. The team typically has members from various areas of the plant, including operations, maintenance, engineering, administration, and plant management. Process Safety Information KMCO keeps a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Chemical-specific information, including exposure hazards and emergency response/exposure treat ment considerations, is provided in material safety data sheets (MSDSs). For specific process areas, KMCO has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) in PHA documentation. KMCO ensures that the process is maintained within these limits by using process controls and monitoring instruments, trained personnel, and protective instrument systems (e.g. automated shutdown systems). KMCO also maintains documents that provide information about the design and construction of process equipment. This information may include materials of construction, design pressure and temperature ratings, electrical rating of equipment, etc. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating prop9osed process and facility changes to ensure that safety features in the process are not compromised. Process Hazard Analysis KMCO has established programs to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. The PHA team findings and/or action items are forwarded to appropriate personnel. All approved mitigation options being implemented in response to PHA team findings are tracked until they are complete. The final resolution of each finding is documented and retained. These periodic reviews are conducted at least every 5 years and will be conducted at this frequency until the process is no longer operating. The results and findings from these updates are documented and retained. Once again, the team findings are forwarded to appropriate personnel for consideration, and the final resolution of the findings is documented and retained. Operating Procedures KMCO is ISO 9002 certified. KMCO maintains written procedures that address various modes of process operations, such as (1) unity startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. Procedures are maintained current by revising them as necessary to reflect changes made through the management of change process. Training To complement the written procedures for process operations, KMCO has implemented a training program for employees involved in operating a process. New employees receive basic training in KMCO plant operations if they are not already familiar with such operations. Afte r successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After operators demonstrate (e.g. through skill demonstration, etc.) having adequate knowledge to perform the duties and task in a safe manner on their own, they can work independently. In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at least every 3 years. All of this training is documented for each operator, including the means used to verify that the operator understood the training. Contractors KMCO uses contractors to supplement its work force during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, KMCO has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have the appropri ate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform KMCO plant personnel of any hazards that they find during their work. Pre-startup Safety Reviews (PSSRs) KMCO conducts a PSSR for any new facility or facility modification that requires a change in the process safety information. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and the equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to make sure construction is in accordance with the design specifications and that all-supporting systems are operationally ready. Mechanical Integrity KMCO has practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include: (1) conducting training, (2) developing written procedures, (3) performing inspections, (4) correcting identified deficiencies, and (5) applying quality assurance measures. Written procedures help ensure that work is performed in a consistent manner and provide a basis for training. Inspections and tests are performed to help ensure that equipment functions as intended, and to verify that equipment is within acceptable limits. If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), or an MOC will be distributed to appropriate personnel to review the use of equipment and determine what actions are necessary to ensure the safe operation of the equipment. Safe Work Practices KMCO has safe work practices in place to help ensure worker and process safety. Examples of these include (1) control of the entry/presence/exit of support personnel, (2) a lockout/tag out procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous materials before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e. hot work), and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. Management of Change KMCO has a comprehensive system to manage changes to processes. This system requires that changes to items such as process equipment, chemicals, technology (including process being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, process op erating limits, and equipment information, as well as procedures are updated to incorporate these changes. In addition, operating and maintenance personnel are provided with any necessary training on the change. Incident Investigation KMCO investigates incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to the HSE Department for filing, recommendations are tracked until they are complete. Compliance Audits Compliance audits are conducted at least every 3 years under PSM and will also be conducted under the RMP Rule. Both hourly and management personnel may participate as audit team members and typic ally a third-party consultant is hired to assist in the audit. The audit team develops findings that are forwarded to KMCO plant management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained. Chemical-specific Prevention Steps The processes at KMCO have hazards that must be managed to ensure continued safe operation. The prevention program summarized previously is applied to all Program 3 EPA RMP - covered processes at KMCO. Collectively these prevention program activities help prevent potential accident scenarios that could be caused by (1) equipment failures and (2) human errors. In addition to the accident prevention program activities, KMCO has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release. The followi ng types of safety features are used in various processes: Release Detection 7 Ethylene Oxide detectors 7 Process alarms Release Containment/Control 7 Process relief valves that discharge to a flare to capture and incinerate episodic releases 7 Scrubber to neutralize chemical releases 7 Valves to permit isolation of the process (manual or automated) 7 Automated shutdown systems for specific process parameters (e.g. high level, high temperature) 7 Curbing or diking to contain liquid releases 7 Redundant equipment and instrumentation for temperature 7 Atmospheric relief devices Release Mitigation 7 Fire suppression and extinguishing systems 7 Deluge system for specific equipment 7 Trained emergency response personnel 7 Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus) 1.5 Five-Year Accident History No releases of Ethylene Oxide, Propylene Oxide, Ethylenediame, Formaldehyde Solution (Formalin) have occurred from KMCO in the last fiv e years that have resulted in deaths, injuries, or significant property damage on site, or known deaths, injuries, evacuations, sheltering-in-place, property damage, or environmental damage off site. 1.6 Emergency Response Program KMCO coordinates emergency response procedures with the local fire department. KMCO workers will respond to minor events that do not have the potential for significant effect (e.g., small fires or small leaks). In the event of a larger fire or release, workers and contractors may evacuate the area if necessary and contact the local fire department. The emergency response team (ERT) is trained to respond to larger fires and releases. Their ERT training includes annual Fire School training at Texas A&M (TEEX). KMCO has established a written emergency response plan that has been communicated to local emergency response officials through the local fire department. Regular dialogue is maintained between KMCO and the Fire Chief and Department via two full- time employees are members of the Volunteer Fire Department, and KMCO is a member of the Local Mutual Aid Organization, Mutual Aid Mont Bellveau (MAMB.) 1.7 Planned Changes to Improve Safety KMCO strives to improve the safety of KMCO processes through periodic safety reviews, the incident investigation program, and a program soliciting safety suggestions from the workers. KMCO resolves findings from PHA's, some of which result in modifications to the process. The following types of changes are planned during the next 5 years: 7 Increase the number of Oxide monitors in process areas from 8 to 10. 7 Revisions to personnel training programs 7 Revised written operating procedures |